Tackling modern day slavery during COVID-19

Modern day slavery can be thwarted by disruption techniques if COVID-19 physical distancing makes in-real-life housing inspections impossible, according to one English local authority.

Illegal HMOs are a central part of modern day slavery operations and without them the whole operation is jeopardised, so they act as red flags in uncovering this illegal activity. Local authority intervention can assist partners responsible for clamping down on trafficking, such as the police and the Gangmasters and Labour Abuse Authority (GLAA). 

However, during the COVID-19 pandemic many EH housing officers are not able to carry out physical inspections of properties, including where they suspect an illegal HMO. In Ipswich, EHPs have been employing a variety of techniques, working in partnership with police and the GLAA, to investigate and disrupt illegal HMOs and associated modern slavery operations.    

Section 72(1) of the Housing Act 2004 creates an offence for landlords and agents of running a licensable HMO without a licence. Recent case law, from a judicial review involving Waltham Forest Council, in East London, has clarified that the offence does not require proof of the defendant’s intention or knowledge of wrongdoing.

Ipswich Council has been using this clarification of the law to make landlords and agents of suspected illegal HMOs aware that they cannot turn a blind eye to activities in their properties, and that they must take all reasonable steps to prevent illegal subletting and HMO use.   

Torben Wood, EHP in private sector housing and public protection, urged fellow officers to share information with the local police and the GLAA, who are both still able to physically visit suspected sites.

Wood said: “Migrant workers are being put in accommodation – certainly from what we are seeing in Ipswich – that is severely overcrowded and presents a range of risks under normal circumstances.

“But with COVID-19 on top of it, the fact that they’re in overcrowded conditions, that they are transported in overcrowded people carriers and minibuses, and then exposed to poor working conditions within meat factories for example – which is supposedly causing a hotspot for COVID-19 – then it’s something that I think at the moment is going under the radar.

“The housing side of it needs to be understood better.  For EHPs the issue is then about how best to tackle it. What’s the best approach for dealing with it, given the restrictions on our work.”

Wood further pointed to the recent COVID-19 hotspot among textile workers in Leicester that contributed to a local lockdown. He added: “We don’t want a local lockdown in Ipswich. So, we are working on what we can do about these addresses that are so severely overcrowded.”

*During the pandemic, has your council been taking any new initiatives to tackle modern day slavery? Get in touch with EHN Extra ([email protected]) to share best practice